5 – WhistlebloWing Procedures - Fiat SpA

150
AnnuAl RepoRt
on CoRpoRAte
GoveRnAnCe
WhistlebloWinG
pRoCeduRes
RESOLUTION
Compliance
Officer of Fiat
S.p.A.
Whistleblowings
Committee
Decision Whistleblowings
Register
PROCEDURE IMPLEMENTATION AND DISSEMINATION TOWARD EMPLOyEES
AND THIRD PARTIES
Upon recommendation by the Compliance Officer, the Internal Control Committee evaluates the Whistleblowings
Management Procedure and submits it to the Board of Directors which, having heard the opinion of the Board of
Statutory Auditors, resolves to approve it.
In conformity with local law and regulations, the procedure applies to all Group Companies in all countries.
Adoption of the procedure is reported to the Fiat S.p.A. Internal Control Committee.
The following process shall be implemented to ensure that information concerning the procedure is effectively
disseminated to all Group employees:
n the Fiat S.p.A. CEO sends the text of the procedure to the CEOs and Compliance Officers of each Sector and
Company, empowering them to initiate the dissemination process. This procedure, which will be accompanied
by a cover letter citing the regulations outlined in the Sarbanes-Oxley Act and the principles expressed in
the Code of Conduct and the Compliance Program pursuant to Legislative Decree 231/2001, emphasizes the
importance of uniform methods for handling whistleblowings within the Group, and specifies the objective and
subjective requirements which whistleblowings must meet in order to qualify for further investigation;
n the Whistleblowings Management Procedure is posted on the Corporate Governance area of the Group intranet,
and is translated into the languages used for the Code of Conduct;
n with the consensus of the Sector and Company Human Resources functions, the Compliance Officers
directly inform all Management personnel and invite function heads to take appropriate action to inform their
associates;
n the internal news bulletins for each Sector and Company shall feature an excerpt from the Whistleblowings
Management Procedure;
n Isvor courses shall provide an overview of the Whistleblowings Management Procedure (content shall be similar
to that published in the news bulletins).
Approved: Board of Directors Meeting of 23 December 2004
Effective: 1 January 2005
Revision: Board of Directors Meeting of 20 February 2007
Compliance Officer of
Fiat S.p.A. and Sector/
Company Compliance
Officer
Measures Board of Statutory Auditors and Internal
Control Committee
Management
Whistleblower
if identified
Subject of
whistleblowing